Datenschutzerklärung | Freestar HR-Services AG

DATENSCHUTZERKLÄRUNG FREESTAR HR-SERVICES AG

1. Scope

This Privacy Policy informs you how and for what purposes Freestar HR-Services Ltd processes your personal data (hereinafter referred to as "you") (hereinafter referred to as "we" or "Freestar HR-Services Ltd").

"Personal data" means any data and information relating to an identified or identifiable natural person.

We process personal data in accordance with the requirements of the Swiss Federal Act on Data Protection (hereinafter "FADP") and, if and to the extent applicable, in accordance with the EU General Data Protection Regulation (hereinafter "GDPR") and local data protection laws. Where we deem it appropriate, we may provide you with additional privacy policies.

Your contact person for any questions regarding data protection is:

Freestar HR-Services AG Stefanie Renger

Victor von Bruns-Str. 19

CH-8212 Neuhausen

Direct dial +41 52 675 35 67

Head office +41 52 675 35 35

Email: srenger@freestar.ch

If you have any questions about data protection at FREESTAR HR-SERVICES AG, please contact the above address.

2. Data origin and data categories

We primarily process personal data that we receive or collect from our clients (including their employees, shareholders, directors, etc.), website visitors, service providers, banks and other business partners in the course of our business activities. In addition, we may also process personal data that we have obtained from publicly accessible sources (e.g. websites or public registers such as the commercial register, etc.). Finally, we may also have received your personal data from your family members, from our business partners, from official bodies and authorities or from other third parties.

The personal data we process includes, in particular, name and contact details (e.g. address, telephone number and e-mail address), identification and background information (e.g. passport number, ID number, language, date of birth, nationality, gender, religious denomination), political data, job title and business relationship, country of residence, geographical location, origin-related data, family situation (e.g. marital status, number of children), data relating to criminal proceedings, financial information for payment purposes (e.g. bank details), economic data (e.g. financial assets, origin of funds), transaction data (e.g. investment profile, risk profile, suitability test, asset allocation, investments).e.g. financial assets, origin of funds), transaction data (e.g. investment profile, risk profile, suitability test, asset allocation, investments).e.g. bank details), economic data (e.g. financial assets, origin of funds), investment-related data (e.g. investment profile, risk profile, suitability test, asset allocation, investments). investment profile, risk profile, suitability test, asset allocation, investments), transaction data (e.g. payment instructions, investment instructions), information about the use of our websites and information of any kind from correspondence, contacts and interactions (e.g. photos, videos and voice recordings) with us.

3. Purpose and legal basis of processing

3.1 In connection with our business activities we process your personal data primarily to provide our services in connection with our business activities. In particular, we process your personal data for the following purposes:

to communicate with you, in particular to provide you with information or to process your requests.
If you contact us by e-mail/contact form, you authorize us to reply to you via the same channel. Please note that unencrypted e-mails are transmitted via the open Internet, which is why it cannot be ruled out that they can be viewed, accessed and manipulated by third parties. We therefore ask you not to send us any confidential information by e-mail. We exclude - to the extent permitted by law - any liability that you may incur, in particular due to incorrect transmission, falsification of content or disruption of the network (interruption, overloading, unlawful interference, blocking);
to provide you with our services and our websites and to evaluate and improve them
to organize and report on events and webinars or to make them available on our websites (e.g. in the form of texts, photos, videos and voice recordings)
for the conclusion, administration and performance of our contractual relationships
to maintain and manage the business relationship with you (including issuing invoices)
to keep you informed of the latest developments or to provide you with other information about our services
to promote our services
for statistical purposes;
for IT and building security reasons (e.g. access controls, visitor lists, network and mail scanners, telephone records) and risk control;
for the assertion of legal claims and defense in connection with legal disputes and proceedings before authorities
to comply with our legal obligations at national and international level.

We process your personal data for the above-mentioned purposes, depending on the situation, in if the processing of personal data is necessary for the performance of a contract with you:

you have given your consent to the processing of personal data concerning you
the processing of personal data is necessary for compliance with a legal obligation
processing is necessary in order to protect the vital interests of the data subject or of another natural person; or
if we have a legitimate interest in processing the personal data.

3.2 When you visit our website

Each time a user accesses our websites, our server collects a range of user information that is stored in the server's log files. The information collected includes the IP address, the date and time of access, the time zone difference compared to GMT, the name and URL of the downloaded file, the website from which access is made, the browser used and the operating system used.

The use of this general data and information does not result in the identification of a specific person. The collection of this information or data is technically necessary in order to display our web pages to you and to ensure their stability and security. This information is also collected in order to improve the websites and analyze their use. The legal basis for the temporary storage of information and log files is our legitimate interest in being able to offer you our websites in sufficient quality and to continuously improve them.

3.3 Contact form and contact by email and telephone

You can contact us via the contact form or via the e-mail addresses and telephone numbers provided on our websites. The personal data that you send us will be stored and processed by us for the purpose of processing your inquiry. The legal basis for this processing of personal data is your consent and our legitimate interest in processing your request.

3.4 Cookies/Tools

Our websites may use cookies or other technologies/tools such as pixels, tags or external services

(hereinafter referred to as "cookies" or "tools"). Cookies are text files that are stored in or by the internet browser on the user's computer system or mobile device. The cookie contains a characteristic string of characters that enables the browser or mobile device to be uniquely identified when the website or app is called up again.

The purpose of using cookies is, on the one hand, to enable and simplify the use of our websites for users. Some functions of the websites cannot be offered without the use of cookies (so-called technically necessary cookies). On the other hand, we use cookies/tools to analyze user behavior on our websites, namely for reach measurement and marketing purposes.

3.4.1 Technically necessary cookies

Technically necessary cookies are required for the functioning of our websites. Therefore, these cookies cannot be deactivated in our systems. These cookies usually record important actions, such as the number of requests, your data protection settings or the completion of forms. Although you can block these cookies in your browser, some parts of our websites may then no longer work.

The legal basis for data processing when using technically necessary cookies is our legitimate interest, which lies primarily in ensuring the functionality and improvement of our websites.

3.4.2 Analytical and marketing cookies

Analytical cookies enable us to analyze visitor behavior and traffic sources so that we can measure the performance of our websites and improve user-friendliness. They help us to identify which pages are popular and how visitors move around our websites. The information collected is aggregated and anonymous.

Marketing cookies allow us to provide you with advertising that is relevant to you. These cookies can remember that you have visited our websites and share this information with other companies, including other advertisers.

When we use cookies for analytics and marketing purposes, we obtain your consent to do so. The processing of data for analysis and marketing purposes is therefore based on your consent. If you give us your consent, you can withdraw it at any time with effect for the future. However, this does not affect the lawfulness of the processing that took place on the basis of your consent prior to the withdrawal of your consent. You can express your revocation at any time by adjusting the cookie settings.

You can object to the use of cookies by, for example, (i) making the appropriate settings in your browser or (ii) using suitable cookie blocker software (e.g. Ghostery, etc.).

3.4.2 Google Analytics

This website uses functions of the web analytics service Google Analytics, based on your explicit consent. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. In exceptional cases, data processing may also be carried out by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

Google Analytics uses so-called “cookies”, which are text files stored on your device that enable an analysis of your use of this website. The information generated by the cookie about your use of this website is usually transmitted to a Google server and stored there.

The use of Google Analytics is based exclusively on your consent in accordance with Art. 6 para. 1 lit. a GDPR. Consent is obtained via our cookie banner and can be withdrawn at any time with effect for the future by accessing the cookie settings again and adjusting your selection.

IP Anonymization

We have activated IP anonymization on this website. This means that your IP address will be shortened by Google within Member States of the European Union or in other states party to the Agreement on the European Economic Area before being transmitted. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there.

On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activities, and to provide other services related to website and internet usage. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

Withdrawal of Consent

You may withdraw your consent at any time by reopening the cookie banner or using the link in the footer to access the cookie settings and disable Analytics cookies.

Browser Plugin

You can also prevent cookies from being stored by adjusting your browser settings. In addition, you can prevent Google from collecting the data generated by cookies relating to your use of the website (including your IP address), as well as the processing of this data, by downloading and installing the browser plugin available at:
https://tools.google.com/dlpage/gaoptout?hl=en

Data Processing Agreement

We have entered into a Data Processing Agreement with Google and comply fully with the strict requirements of European data protection authorities when using Google Analytics.

Demographic Data

This website uses the “demographic features” function of Google Analytics. This allows reports to be created that provide information on the age, gender, and interests of visitors. These data originate from interest-based advertising by Google and from third-party visitor data. The data cannot be assigned to a specific person. You can disable this feature at any time in your Google account ad settings.

Storage Period

Data stored by Google at user and event level that are associated with cookies, user identifiers (e.g., User ID), or advertising IDs (e.g., DoubleClick cookies, Android advertising ID) are anonymized or deleted after 50 months.

Further details can be found here:
https://support.google.com/analytics/answer/7667196?hl=en

Further information on how Google handles user data can be found in Google’s Privacy Policy:
https://support.google.com/analytics/answer/6004245?hl=en

3.5 Google Tag Manager

We may use Google Tag Manager from Google on our websites. Google Tag Manager is a solution that enables us to manage website tags via a single interface. The tool itself is a cookie-free domain and, according to Google, does not collect any personal data. The tool triggers other tags, which in turn may collect personal data. Google Tag Manager has no access to this data. If a deactivation has been made at domain or cookie level, this remains in place for all tracking tags implemented by Google Tag Manager. You can prevent the setting of tags at any time.

The legal basis for this is your consent and our legitimate interests.

3.6 YouTube videos

We can embed videos from the YouTube platform on our websites so that they can be played directly from our websites. The YouTube videos are all embedded in "extended data protection mode", which means that no data about you as a user is transmitted to YouTube if you do not play the videos. Only when you play the videos will data about you be transmitted.

The legal basis for the processing of your data is your consent. Further information about the processing of personal data by Google Ireland Limited in connection with the playing of YouTube videos can be found at https://policies.google.com/privacy?hl=en&gl=de.

3.7 Google Maps

We may use the Google Maps plugin from Google Ireland Limited or Google LLC, USA, on our websites. If you use Google Maps on our websites, information about the use of our websites (incl. IP address) may be transmitted to a Google server in the USA and also stored on this server. We have no knowledge of the exact content of the transmitted data or of its use by Google. However, data about you as a user will only be transmitted to Google if you activate the content of Google Maps on our websites.

The legal basis for the processing of your data is your consent. Further information on the data protection provisions and terms of use for Google Maps can be found at the following link: https://www.google.com/intl/en_de/help/terms_maps.

3.8 Plug-ins for social media

We may use the social media plug-ins listed in the following table on our websites. We use the so-called two-click solution, i.e. when you visit our websites, no personal data is passed on to the providers of the plug-ins. Only when you click on the selected plug-in field and activate the plug-in will the provider be informed that you have visited our websites. In addition, the data specified in section 3.2 of this privacy policy will be transmitted. The legal basis for the processing of your data in connection with the social media plug-ins is our legitimate interest in enabling our users to use the social media plug-ins.

We have no control over the data collected and data processing operations of the plug-in providers. These are subject to the respective data protection provisions of the third-party providers. Further information on the purpose and scope of data collection and its processing by the plug-in provider can be found in the privacy policies of these providers listed below.

Plug-in Provider and privacy policy
LinkedIn - LinkedIn Ireland Unlimited Company: https://www.linkedin.com/legal/privacy-policy
Instagram - Meta Platforms Ireland Limited:
https://privacycenter.instagram.com/policy/?entry_point=ig_help_
center_data_policy_redirect&__coig_consent=1
Xing - New Work SE:
https://privacy.xing.com/de/datenschutzerklaerung
Jobshot - https://www.jobshot.ch/datenschutz

3.9 Applications

You can submit your application for a position with us by post or via the e-mail addresses provided

on our websites. Your application documents and all personal data that you provide to us will be treated in strict confidence, will not be passed on to third parties and will only be processed for the purpose of processing your application for a position with us. Unless you have given your consent to the contrary, your application file will either be returned to you or deleted/destroyed after completion of the application process, unless it is subject to a statutory retention obligation. The legal basis for the processing of your data is your consent, the fulfillment of the contract with you and our legitimate interests.

4. Transfer of personal data to recipients and abroad

4.1 Transfer of personal data to recipients

In addition to the transfer of data to the recipients expressly named in this Privacy Policy, we may - where permitted - transfer personal data to the following categories of recipients:

Other companies belonging to the Freestar Group;
Providers to whom we have outsourced certain services (e.g. IT and hosting providers, payment
service providers, debt collection service providers, risk management and compliance providers, etc.);
Service providers, subcontractors and other business partners;
Banks and insurance companies;
Tax advisors, auditors, lawyers, notaries and other external professional advisors of FREESTAR HR-SERVICES AG
Counterparties;
National and foreign authorities, institutions and courts.

4.2 Disclosure of personal data abroad

Your personal data may be processed in Switzerland, the European Union or the European Economic Area (hereinafter "EU/EEA"), but also in a country outside Switzerland, the EU or the EEA, e.g. in China, Panama, Hong Kong and the USA.

If we transfer data to a country without adequate legal data protection, we ensure an adequate level of protection within the framework of the legal provisions by means of appropriate contracts (namely on the basis of the so-called standard contractual clauses of the European Commission) or we rely on the legal exceptions of consent, contract fulfillment, the establishment, exercise or enforcement of legal claims, overriding public interests, published personal data or because it is necessary to protect the integrity of the data subjects. We would like to point out that data transmitted abroad is no longer protected by Swiss law and that foreign laws and official orders may require the disclosure of this data to authorities and other third parties.

5. Duration of storage

We process and store your personal data only for as long as is necessary for the respective processing purpose or for as long as there is another legal basis for doing so (e.g. statutory retention periods). We retain personal data that we have stored on the basis of a contractual relationship with you for at least the duration of this contractual relationship and the statutory limitation periods for possible claims or on the basis of contractual retention obligations. As soon as your personal data is no longer required for the above-mentioned purposes, it will be inactivated, deleted or anonymized as far as possible.

6. Your rights

According to the data protection law applicable to you, you have the right to information, correction, deletion, the right to restrict data processing and other rights to object to our data processing as well as the right to have certain personal data transferred to another location (so-called data portability). Please note, however, that we reserve the right to assert the legal restrictions on our part, e.g. if we are obliged to retain or process certain data, if we have an overriding interest in doing so (insofar as we are entitled to invoke this) or if we need the data to enforce claims. We will inform you in advance if you incur costs as a result.

If the data processing is based on your consent, you can revoke this consent at any time with effect for the future. However, this does not affect the lawfulness of the processing that took place on the basis of your consent prior to the withdrawal of consent.

The exercise of these rights generally requires that you provide clear proof of your identity (e.g. by means of a copy of an identity document if your identity is otherwise unclear or cannot be verified). To assert your rights, you can contact us at the address given in section 1 of this privacy policy. In addition, every data subject has the right to assert their rights in court or to lodge a complaint with the competent data protection authority. The competent data protection authority may vary depending on your place of residence or the place where the alleged breach of applicable data protection law takes place.

7. Data security

We take appropriate security measures to maintain the necessary security of your personal data and to ensure its confidentiality, integrity and availability, to protect it from unauthorized or unlawful processing and to mitigate the risk of loss, accidental alteration, unauthorized disclosure or access.

8. Changes to this privacy policy

We expressly reserve the right to amend this Privacy Policy at any time. In the event of such a change, we will immediately publish the amended privacy policy on our websites. The privacy policy published on our websites shall apply in its currently valid version.

Neuhausen, 28.10.2025